Taxation (International and Other Provisions) Act 2010
2010 CHAPTER 8
Commentary on Sections
Part 4: Transfer pricing
Chapter 2: Key interpretative provisions
Section 161: Indirect participation: sections 148 and 175: financing cases
334.Under this section an affected person acting with others to provide financing arrangements to the other affected person is treated as indirectly participating in that person’s management, control or capital. It is based on paragraphs 4A(1), (3) to (6) and 6(4C) of Schedule 28AA to ICTA.
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